Last Updated: 19 January 2025
This Privacy Policy describes how Italo Limited ("Italo," "we," "us," or "our") collects, uses, shares, and protects personal information. It applies to information collected through our website www.lrnd.ai, our web app www.app.lrnd.ai, our services, and any other interaction with us, whether online or offline. We are committed to protecting your privacy and handling your personal information responsibly. You can find information about our use of cookies in our Cookies Policy available here.
1. Who We Are
Italo Limited is a company registered in the United Kingdom with company number 15739778 and registered address at 33 Matthew Close, London, United Kingdom, W10 5YL. For the purposes of data protection law, we are the controller of your personal information. Our Data Protection Officer can be contacted at [email protected].
2. Scope
This Privacy Policy applies to individuals who interact with us, including users of our website, clients, prospective clients, and any other individuals from whom we collect personal information.
3. Types of Personal Information We Collect
We collect various types of personal information depending on how you interact with us. These may include:
Identity Data: Name, username, password, title, date of birth, gender.
Contact Data: Billing address, delivery address, email address, telephone numbers.
Financial Data: Bank account details, payment card details, purchase history.
Transaction Data: Details about payments to and from you and other details of products or services you have purchased from us.
Technical Data: Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data: Username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
Usage Data: Information about how you use our website and services.
Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties and your communication preferences.
Content Data: Any content you upload, submit, or otherwise transmit to or through our services.
Special Categories of Personal Data: We do not generally collect special categories of personal data. However, if it is essential for a specific service, we will only collect this with your explicit consent and in line with applicable laws. This includes data concerning your health, religion, political opinions, etc.
Recruitment Data: If you apply for a job with us, we collect data relating to your experience and past employment.
4. How We Collect Your Personal Information
We collect personal information in the following ways:
Directly from you: When you create an account, make a purchase, fill out a form, contact us, or otherwise provide information to us.
Automatically: Through the use of cookies and similar tracking technologies when you visit our website (see our Cookies Policy available here).
From third parties: We may receive information from third parties such as payment processors, analytics providers, or marketing partners with whom we collaborate.
Via recruitment agencies: When you apply for a role through an agency, we will receive the information you provide to them.
5. How We Use Your Personal Information
We use your personal information for the following purposes:
To provide and improve our services.
To manage your account and purchases.
To communicate with you about our products, services, and updates.
To process payments and manage transactions.
To personalize your experience and tailor content to you.
To provide customer support and respond to your requests.
To monitor and improve the performance of our website.
To send marketing communications (where you have consented to receive them).
To comply with legal obligations.
To protect against fraud and illegal activities.
For recruitment purposes if you apply for a role at Italo.
6. Legal Basis for Processing Personal Information
We process your personal information only when we have a lawful basis for doing so. This may include:
Consent: Where you have given us explicit consent to process your information for a specific purpose. You can withdraw your consent at any time.
Contract: Where processing is necessary to fulfill our contractual obligations to you.
Legitimate Interests: Where processing is necessary for our legitimate interests, provided those interests do not override your rights and freedoms.
Legal Obligation: Where processing is necessary to comply with legal requirements.
7. Sharing Your Personal Information
We may share your personal information with:
Service Providers: Third-party service providers who assist us with payment processing, IT services, website hosting, marketing, and analytics.
Affiliates: Companies within our corporate group.
Business Partners: Where it is necessary to provide a joint service.
Law Enforcement: When legally required to do so or to protect our rights or the rights of others.
Professional advisors: Such as lawyers and accountants for legal and tax purposes.
Auth0: We use Auth0, a third-party service provider, for user authentication and account management. This means that when you sign up or log in to our services, some of your personal information (such as your email address and password) is transmitted to and processed by Auth0 in accordance with their privacy policy, which can be found at https://auth0.com/privacy/.
We require these third parties to handle your personal information in accordance with this Privacy Policy and applicable laws. We do not sell your personal information to third parties.
8. International Transfers
Your personal information may be transferred to and processed in countries outside of the UK and the European Economic Area (EEA), including in the United States. In such cases, we will ensure that appropriate safeguards are in place, such as the use of Standard Contractual Clauses, to ensure that your data is protected in accordance with relevant data protection laws. Our third-party authentication provider, Auth0, may transfer your data to and process your data in countries outside of the UK and European Economic Area. Please see Auth0's privacy policy for more information.
9. Your Rights
You have the following rights in relation to your personal information:
Right to Access: You can request access to the personal information we hold about you.
Right to Rectification: You can request that any incorrect or incomplete information is corrected.
Right to Erasure: You can request that your personal information is deleted, subject to legal requirements.
Right to Restriction of Processing: You can request that we restrict the processing of your personal information in certain circumstances.
Right to Data Portability: You can request to receive a copy of your personal information in a structured, machine-readable format.
Right to Object: You can object to the processing of your personal information in certain circumstances, such as for direct marketing purposes.
Right to Withdraw Consent: You can withdraw your consent to the processing of your personal information at any time.
Right to Lodge a Complaint: You can lodge a complaint with the relevant data protection authority if you believe your personal information has been processed unlawfully. In the UK, this would be the Information Commissioner’s Office (ICO).
To exercise your rights, please contact us using the contact details provided in section 13.
10. California Privacy Rights
If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA), including:
Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected about you, the sources of that information, the purposes of collection, and with whom we share your information.
Right to Delete: You have the right to request that we delete personal information that we have collected from you, subject to certain exceptions.
Right to Opt-Out of Sale: While we do not sell your personal information, you have the right to opt-out of the sale of your personal information should we ever start selling data in the future.
Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
To make a request under the CCPA, please contact us using the contact details provided in section 13.
11. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. In determining how long to retain your information, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, and whether we can achieve those purposes through other means, as well as applicable legal requirements.
12. Security
We take appropriate technical and organizational measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include secure storage, access controls, data encryption, and regular security reviews. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
13. Contact Us
If you have any questions about this Privacy Policy or our privacy practices, please contact us at:
Italo Limited
33 Matthew Close, London, United Kingdom, W10 5YL
Email: [email protected]
Data Protection Officer: [email protected]
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on our website and by taking any other appropriate steps. Your continued use of our website or services after any such changes constitutes your acceptance of the new Privacy Policy.